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MEMORANDUM OPINION
WHERRY, Judge: This case is before the Court on petitioner’s
motion to withdraw deemed admissions pursuant to Rule 90(f) and
respondent’s motion for summary judgment pursuant to Rule
121(a).1 Respondent determined the following deficiencies and
additions to tax with respect to petitioner’s Federal income
taxes for the 2000 and 2001 taxable years:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
2000 $186,109 $46,210.00 $9,865.68
2001 87,905 21,976.25 3,513.00
Background
Petitioner submitted to the Internal Revenue Service (IRS) a
Form 1040, U.S. Individual Income Tax Return, for the 2000
taxable year claiming a refund of $1,269.18 for wages withheld
and containing zeros on all other filled out lines between line 6
and line 58 of the tax return. Petitioner similarly submitted a
Form 1040 for the 2001 taxable year that contained zeros on all
filled out lines from line 7 through line 70 of the tax return.
Petitioner also enclosed with his 2000 and 2001 returns a typed
statement challenging his duty to file returns and pay taxes.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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Last modified: May 25, 2011